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Agency Proposed Regulation Essay

862 words - 4 pages

Week 2 Homework Help – GM520.
Professor Dan Speckenzy

Student Name: ECPECO
Date: 1 November 2009

1. Administrative Agency: Federal Energy Regulatory Commission (FERC), of the Department of Energy (DOE)

I chose FERC because it is the federal administration agency that ultimately my employer being a utility and a member of the non-government North American Reliability Commission (NERC) through which FERC imposes energy or electrical power jurisdictional and regulatory control. I chose the 60-day regulation on the books “Reliability Standards for Geomagnetic Disturbances” or RSGD regulation as it will eventually translate into physical, electronic, and IT infrastructure changes ...view middle of the document...

It would be a fair expectation that from these assessments owners, operators, and suppliers would develop and implement procedures and plans to mitigate GMDs, and minimize equipment damage, ensure quick response resulting in electrical power reliability and delivery consistent to the strategies and tactical assertions of the filed reliability standard(s).

3. My comment is that electrical energy is essential to our well being and pursuit of happiness. It is in our national interest hat our nation’s Bulk-Power Systems and resulting power-grid infrastructure needs to be safeguarded and protected to avoid disruptions to our nations commerce and business infrastructures, and national viability. It is ultimately essential for our survival as a global leader and promulgation of our values of freedoms, and representative republic ideals. Its absence is a clear and present danger to our national security if this is not addressed. The ensuing chaos and devastation of power outages in massive scale never-seen before was recently evidenced in 2004’s Northeastern U.S. cascading power outage cascading from the Ohio power corridor through Pennsylvania into the New England states, and even more recently with super storm Sandy on New York, New Jersey, Connecticut and other New England states.

4. The public comment deadline: 24 December, 2012

5. Challenges to Proposed Rules

a. Hypothetically if I was against the regulation, and it was not withdrawn before promulgation, during the promulgation process, I would challenge the regulation to a administrative court judge using one or a combination of the five recognized legal theories.

b. The five recognized legal theories that I could use...

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